UBS, and a Georg Fischer group pension fund as UBS' customer, asked Pestalozzi to advice on a transfer of the pension fund's complete direct real estate investments portfolio. The transfer was made in exchange for shares in a regulated UBS real estate fund. The deal was particularly challenging from a tax perspective. In addition, the transaction was governed by complex restrictions under local real estate laws which had to be mitigated. The tax authorities treated the transaction as a leading case and redefined their practice in this area. Pestalozzi advised UBS on all tax and legal aspects of the transaction and negotiated with the tax authorities a way for the real estate asset swap to be made in a tax neutral way.